Consent to the processing of biometric data
Last updated: 22 September 2026 · version 1.3
This is a separate consent. It is not part of the Terms of Service and ticking the box that accepts the Terms is not a consent to what is described here.
It covers only the photographs of your face. We ask for it separately because those photographs are a special category of personal data under Art. 9 of the GDPR and the only lawful ground available for them is your explicit consent under Art. 9(2)(a).
The exact wording you tick before uploading:
I consent to the processing of my photographs for the purpose of creating new photographs of my likeness with artificial intelligence. Giving this consent is voluntary but necessary for the service, and I can withdraw it at any time, which deletes my uploaded photographs and the photographs created from them. The photographs will not be shared with or resold to third parties.
1. What exactly you are consenting to
You consent to archBO s.r.o. (LookTwin), Korunní 2569/108, 101 00 Prague, Czech Republic, IČO 01944711, processing the photographs of your face that you upload, for the single purpose of creating new photographs of your likeness.
This means your photographs are stored with us in the European Union and serve as references from which artificial intelligence creates new photographs. No permanent model of your likeness is created from them — every photograph is created anew from these references. They are not used for anything else.
We treat these photographs as biometric data. We do not use them to identify or verify anyone, we do not compare them against any database, and we do not build any face-recognition function.
Before you decide, we create several preview portraits from your uploaded photographs, visibly marked LookTwin, so you can pick the ones that look most like you. This consent covers those previews as well.
2. Who processes the photographs
fal — Features and Labels, Inc., San Francisco, United States: operates the artificial-intelligence models that create new photographs from your references. The transfer to the United States is based on the EU Standard Contractual Clauses (Commission Implementing Decision (EU) 2021/914, Module 2). fal is contractually bound not to use your content to create, train or develop its own products or services, and we instruct it to keep nothing beyond what is needed to create the photographs.
Supabase: stores your uploaded photographs and the created photographs in our private storage, in the EU region eu-central-1 (Frankfurt).
Vercel: hosts and delivers the application through which the photographs are uploaded.
Nobody else receives your photographs. We do not use them for marketing, references or portfolio, and we do not use them — nor allow anyone else to use them — to train, improve or develop any AI model.
3. This consent is voluntary
Giving this consent is entirely voluntary. Nothing bad happens if you refuse it: you simply cannot use the service, because processing the photographs of your face is the whole substance of what LookTwin does.
The box is not ticked in advance. Consent is given only by ticking it yourself, before any photograph is uploaded. We ask for it before every order.
4. You can withdraw it at any time
You can withdraw this consent at any time, as easily as you gave it, and free of charge. In the application, open Account and press the button Withdraw consent and delete everything. It marks all of your consents as withdrawn and deletes all of your orders together with the photographs you uploaded for them and the photographs created from them. You can also write to info@looktwin.com.
Deleting a single order in the application has the same effect for that order. If it was your last order, the consent to the processing of the photographs of your face is marked as withdrawn as well, and you are asked for it again before any future order.
Withdrawal means we can no longer process your photographs. In practice it therefore deletes the uploaded references and the photographs created from them. An order that is in progress is not waited for; it is deleted with them.
Withdrawal does not close your account. If you have paid for a package and have finished photographs, withdrawing this consent deletes those photographs as well — download them before you withdraw. If you also want the account itself deleted, write to info@looktwin.com.
Withdrawal does not affect the lawfulness of the processing carried out before it, and it does not delete records we must keep by law (accounting records and the record that a consent was given and withdrawn).
5. What we record as evidence of consent
To be able to demonstrate that consent was given (Art. 7(1) GDPR), we store: your user identifier, the kind of consent, the version of this text, the time it was given, and a salted hash of the IP address from which it was given.
We do not store the raw IP address in the consent record, and the hash cannot be used to look you up by address.
6. More information
Retention periods, your rights, the supervisory authorities and the full list of processors are described in the Privacy Policy.
Questions about this consent: info@looktwin.com.
archBO s.r.o., IČO 01944711, Korunní 2569/108, 101 00 Prague, Czech Republic, registered in the Commercial Register kept by the Municipal Court in Prague, file no. C 285018. Telephone +420 725 543 392, e-mail info@looktwin.com.